Regulatory Disclosures

Polinvest operates as an investment facilitation platform, capital markets arranger, and fund management firm. The following disclosures are provided in accordance with applicable regulatory requirements and in the interest of transparency with our clients, investors, and counterparties.

1. Regulatory Status

Polinvest conducts investment facilitation, capital markets advisory, and fund management activities across multiple jurisdictions. The specific regulatory status of our activities varies by jurisdiction and activity type. We are committed to operating in full compliance with applicable licensing, registration, and conduct requirements in each market where we are active. Clients and counterparties seeking confirmation of our regulatory status in a specific jurisdiction should contact our compliance team.

2. Investment Risks

All investment and lending activities facilitated by Polinvest carry inherent risk, including the risk of total or partial loss of capital. The value of investments can fall as well as rise, and returns are not guaranteed. Past performance of any transaction or fund managed by Polinvest is not indicative of future performance. Prospective investors and borrowers should carefully consider the risks associated with any proposed transaction before committing capital.

Specific risks associated with Polinvest-arranged transactions include, but are not limited to: credit risk, the risk that a borrower fails to meet its repayment obligations; market risk, the risk that changes in interest rates, exchange rates, or commodity prices adversely affect the value of an investment; liquidity risk, the risk that an investment cannot be sold or exited at the expected price within the expected timeframe; and operational risk, the risk of loss resulting from inadequate or failed internal processes, systems, or external events.

3. Conflicts of Interest

Polinvest operates across capital markets advisory, loan syndication, and fund management, activities that may from time to time give rise to conflicts of interest. We maintain a formal conflicts of interest policy that governs how identified conflicts are managed and disclosed. Our key principles are: transactions are allocated fairly and transparently across our fund and advisory client base; investment committee decisions are made independently of commercial pressures; and all material conflicts are disclosed to affected parties prior to any transaction commitment.

4. Fees and Remuneration

Polinvest earns fees from both arranging transactions on behalf of borrowers and issuers (arrangement fees, agency fees) and from managing investment funds (management fees, carried interest). The existence of both fee streams creates a potential incentive to arrange transactions and manage assets in ways that maximise fee income rather than investor returns. We manage this conflict through our investment committee governance, independent fee benchmarking, and full disclosure of our fee structure to all clients and investors prior to engagement.

5. Third-Party Information

Transaction information memoranda and investment materials prepared by Polinvest incorporate information provided by borrowers, issuers, and other third parties. While we conduct due diligence to verify key representations, we cannot guarantee the accuracy or completeness of all third-party information. Investors and lenders should conduct their own due diligence and not rely solely on Polinvest-prepared materials in making investment decisions.

6. Sustainability and ESG

Polinvest considers environmental, social, and governance factors in its investment and lending decisions. We apply an exclusion list that prohibits transactions involving weapons, gambling, tobacco, and other activities inconsistent with our ESG principles. For infrastructure and project finance transactions, we reference the Equator Principles as a benchmark for environmental and social risk assessment. Our ESG policy is available on request.

7. Complaints Procedure

We take all complaints seriously. If you wish to make a formal complaint about our services or conduct, please submit it in writing to our compliance team via the contact page. We will acknowledge all complaints within three business days and aim to provide a full response within 20 business days. If you are not satisfied with our response, you may escalate the matter to the relevant regulatory authority in your jurisdiction.